Interconnection for Wind Energy and Other Alternative Technologies, 012405 FERC, RM05-4-000

Docket Nº:RM05-4-000
Party Name:Interconnection for Wind Energy and Other Alternative Technologies 18 CFR Part 35
Judge Panel:Linda Mitry, Deputy Secretary.
Case Date:January 24, 2005
Court:Federal Energy Regulatory Commission

Interconnection for Wind Energy and Other Alternative Technologies

No. RM05-4-000

18 CFR Part 35

United States of America, Federal Energy Regulatory Commission

January 24, 2005

AGENCY: Federal Energy Regulatory Commission.

ACTION: Notice of Proposed Rulemaking.

SUMMARY: The Federal Energy Regulatory Commission (Commission) is proposing to amend its regulations to require public utilities to append to the standard large generator interconnection agreement in their open access transmission tariffs (OATTs) specific technical requirements for the interconnection of large wind generation.

DATES: Comments are due [insert date 30 days after publication in the FEDERAL REGISTER]. Reply comments will be due 30 days thereafter.

ADDRESSES: Comments may be filed electronically via the eFiling link on the Commission's web site at Commenters unable to file comments electronically must send an original and 14 copies of their comments to Federal Energy Regulatory Commission, Office of the Secretary, 888 First Street N.E., Washington, DC, 20426. Refer to the Comment Procedures section of the preamble for additional information on how to file comments.


Bruce A. Poole (Technical Information)

Office of Markets, Tariffs and Rates

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, DC 20426

(202) 502-8468

G. Patrick Rooney (Technical Information)

Office of Markets, Tariffs and Rates

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, DC 20426

(202) 502-6205

P. Kumar Agarwal (Technical Information)

Office of Markets, Tariffs and Rates

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, DC 20426

(202) 502-8923

Jeffery S. Dennis (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, DC 20426

(202) 502-6027




1. In Order No. 2003, 1] the Commission adopted standard procedures for the interconnection of large generation facilities and a standard large generator interconnection agreement. The Commission required public utilities that own, control, or operate facilities for transmitting electric energy in interstate commerce to file revised Open Access Transmission Tariffs (OATTs) containing these standard provisions, and use them to provide interconnection service to generating facilities having a capacity of more than 20 megawatts. In Order No. 2003-A, on rehearing, the Commission determined that the standard procedures and agreement were designed around the needs of traditional synchronous generation facilities, and that generators relying on non-synchronous technologies, 2] such as wind plants, may find that a specific requirement is inapplicable or that a different approach is needed.3] Accordingly, the Commission granted certain clarifications, and also added a blank Appendix G (Requirements of Generators Relying on Non-Synchronous Technologies) to the standard generator interconnection agreement as a placeholder for the inclusion of requirements specific to non-synchronous technologies.4] It appears that the only relevant non-synchronous generator in this rulemaking is the wind generator, and thus the proposed rule would apply only to wind plants, although we request comments on whether there are other technologies that should also be subject to the rule.

2. In this Notice of Proposed Rulemaking (NOPR), the Commission is proposing standards applicable to the interconnection of large wind generating plants, 5] to be included in Appendix G of the Large Generator Interconnection Agreement (LGIA). The Commission proposes these standards in light of its findings in Order No. 2003-A, noted above, and in response to a petition submitted by the American Wind Energy Association (AWEA) on May 20, 2004. Specifically, and as described more fully below, we propose to include in Appendix G to the LGIA certain technical requirements that Transmission Providers must apply to interconnection service for wind generation plants that are different from that required of traditional synchronous generating plants or are now needed because of the increased presence of larger aggregated wind plants on the Transmission Provider’s systems. These requirements would be applied in addition to the standard interconnection procedures and requirements adopted by the Commission in Order No. 2003. Additionally, the Commission seeks comments on certain issues, including whether there are other non-synchronous technologies, or other technologies in addition to wind, that should also be covered by the proposed Appendix G.


3. In Order No. 2003, pursuant to its responsibility under sections 205 and 206 of the Federal Power Act (FPA)6] to remedy undue discrimination, the Commission required all public utilities that own, control, or operate facilities for transmitting electric energy in interstate commerce to append to their OATTs the pro forma Large Generator Interconnection Procedures (LGIP) and pro forma LGIA. To achieve greater standardization of interconnection terms and conditions, Order No. 2003 required such public utilities to file revised OATTs containing the pro forma LGIP and LGIA included in Order No. 2003.

4. Order Nos. 2003-A and 2003-B, issued on rehearing, made certain revisions to the pro forma LGIP and LGIA. In Order No. 2003-A, the Commission clarified that certain provisions of the LGIP and LGIA are not appropriately applied to wind generators. The Commission stated that it “recognize[d] that the LGIA and LGIP are designed around the needs of large synchronous generators and that many generators relying on newer technologies may find that either a specific requirement is inapplicable or that it calls for a slightly different approach.”7] In light of this recognition, the Commission clarified that LGIA article 5.4 (Power System Stabilizers), LGIA article 5.10.3 (Interconnection Customer’s Interconnection Facilities Construction) and LGIA article 9.6.l (Power Factor Design Criteria) would not be applied to wind generators.8] Additionally, the Commission noted that “there may be other areas of the LGIP and LGIA that may call for a slightly different approach for a generator relying on newer technology because it may have unique electrical characteristics.”9] As a result, the Commission added to the LGIA a blank new Appendix G as a placeholder for requirements specific to newer technologies to be developed at a future time.10

5. On May 20, 2004, in Docket No. RM02-1-005, AWEA submitted a petition for rulemaking or, in the alternative, request for clarification of Order No. 2003-A, and a request for a technical conference. AWEA asked the Commission to adopt in Appendix G certain standards for the interconnection of wind generation plants. Specifically, AWEA submitted a proposed Appendix G that it argues addresses the concerns of both Transmission Providers and the wind generation industry. AWEA’s proposed Appendix G included a low voltage ride-through capability standard, which would allow the Transmission Provider to require as a condition of interconnection that wind generation facilities have the ability to continue operating or “ride-through” certain low voltage conditions on the transmission system to which they are interconnected. Additionally, AWEA proposed that the power factor design criteria of up to 0.95 leading/lagging be applied to wind generation plants, with certain flexibility regarding whether the location of the reactive support equipment would be at the common point of interconnection of all the generators in the plant rather than at the individual turbine. Further, AWEA proposed that we require Transmission Providers and wind generator manufacturers to participate in a formal process to develop, update, and improve the engineering models and specifications used in modeling wind plant interconnections. Finally, AWEA proposed to include language in Appendix G allowing the wind Interconnection Customer to “self-study” interconnection feasibility by entering the interconnection queue without providing certain power and load flow data, receiving certain information from the Transmission Provider, and conducting its own Feasibility Study.

6. On September 24, 2004, the Commission held a Technical Conference to discuss the issues raised by AWEA’s petition. The goal was to discuss the technical requirements for the interconnection of wind plants and other alternative technologies and the need for specific requirements for their interconnection. Additionally, the Technical Conference considered how wind and other alternative generator technologies may respond differently to transmission grid disturbances and have different effects on the transmission grid. The Commission also solicited and received post-Technical Conference comments from interested persons.


7. Based on our review and consideration of AWEA’s petition and the comments received at and after the Technical Conference, the Commission is proposing certain technical requirements for the interconnection of wind generating plants. The Commission proposes to include these technical requirements as Appendix G to the LGIA, as contemplated in Order No. 2003-A. The technical requirements we propose here are similar in certain respects and differ in other respects from the Appendix G proposed by AWEA in its petition for rulemaking. The Commission is also seeking comments on certain issues, as discussed below. Our goal is to...

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